New and Interesting International Tax Issues

Authority - Treasury Decisions

December 15, 2016

Last month, the IRS released Treasury Decision 9792, which included final regulations under Code §956. The final regulations include rules regarding U.S. property held by controlled foreign corporations ("CFCs") in transactions involving partnerships. There were 23 examples in the regulations, and we have created new situational charts that illustrate all 23 of the examples. The charts are available at http://andrewmitchel.com/topic.php#sec956, where you can find hundreds of other situational charts.
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February 11, 2010

On December 17, 2009, the I.R.S. and the Treasury Department issued final regulations (Treasury Decision 9475) dealing with “cash D” reorganizations. In drafting the regulations, the IRS and Treasury Department analyzed whether the “meaningless gesture doctrine” is inconsistent with the distribution requirement in Code §§ 368(a)(1)(D) and 354(b)(1)(B), especially in situations in which the cash consideration received equals the full fair market value of the property transferred. In this circumstance, the regulations adopt a rule...
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February 27, 2009

On February 10, 2009 the I.R.S. and Treasury Department issued temporary regulations in Treasury Decision 9444 regarding the application of Code § 367(a) and (b) with respect to Code § 304 transactions. Code § 367(a)(1) generally provides that if a United States person transfers property to a foreign corporation in an exchange described in Code § 332, 351, 354, 356, or 361, the foreign corporation shall not be considered a corporation for purposes of determining...
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Disclaimer

The posts on this blog have not been verified for accuracy. You should consult an attorney for legal advice regarding your own situation. These posts are not updated for changes in the tax laws. Further, these posts should not be relied upon for any purpose whatsoever.